Effective Date: September 23, 2013
TRIHEALTH SCHOOL-BASED BEHAVIORAL HEALTH PROGRAM NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION, PLEASE REVIEW IT CAREFULLY.
This Notice will tell you about the ways in which we may use and disclose medical information about you. It also describes your rights and certain obligations that we have regarding the use and disclosure of your medical information.
Bethesda Healthcare, Inc. ("TriHealth") is covered by regulations pursuant to the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and is required by law to maintain the privacy of your medical information, give you notice of breaches of your unsecured medical information, give you notice of our privacy practices with respect to your medical information, and to abide by the terms of this Notice currently in effect. This Notice applies to the records of your care generated and maintained by Bethesda Healthcare, Inc.'s d.b.a. TriHealth Community Outreach School-based Behavioral Health Program (the "School-Based Program") which is operated at one or more Cincinnati, Ohio area schools.
Medical information for purposes of this Notice means information about your physical or mental health which could identify you, including mental/behavioral conditions which make you eligible for our services, or which arise while we are serving you. Medical information may include psychological test results and information regarding counseling services you receive from us.
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU:
The following categories describe different ways that we may use and disclose your medical information. These are examples and, therefore, not every permitted use and disclosure is listed.
We may use medical information about you to provide you with behavioral health therapy, individual or group counseling, classroom observation, interventions during the school day and psychological testing services. We may disclose medical information about you to school counselors, support staff, or other personnel who are involved in providing your mental health services to you. We may also share medical information about you in order to coordinate the different services you need, such as counseling, case management and medical referrals. We may also disclose medical information about you to health care providers outside the School-Based Program who may be involved in your care, such as your family physician, psychologist, or other mental health professional. For Payment. We do not bill for our services, therefore, we will not use and disclose medical information about you for any billing or payment purpose.
For Health Care Operations.
We may use and disclose medical information about you in order to operate the School-Based Program. These uses and disclosures are necessary to run the School-Based Program and make sure that our clients receive quality health care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our counseling staff in caring for you. We may use and disclose medical information about you for various quality assurance and quality improvement activities. We may also provide medical information to other healthcare providers who have a relationship with you and need the information for their own healthcare operations.
We may disclose medical information about you to our business associates who need that information in order to provide a service to us or on behalf of us. A business associate is a person who is not part of TriHealth's workforce, a company or other entity which uses or has access to your medical information in order to perform a function on behalf of the School-Based Program. For example, business associates of TriHealth may include billing companies, copying companies, document shredding companies, consultants, accountants and attorneys.
We may use and disclose your medical information to contact you as a reminder that you have an appointment for counseling or other services from the School-Based Program.
We may use and disclose your medical information to tell you about or recommend possible treatment/therapy options or alternatives that may be of interest to you.
Health-Related Benefits and Services.
We may use and disclose your medical information to tell you about health-related benefits or services that may be of interest to you.
Individuals Involved With or Concerned About Your Care.
We may release information about your condition or treatment to a family member relevant to his/her involvement in your care.
Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one behavioral health therapy to those who received another, for the same condition. Research projects are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with patients’ need for privacy of their medical information.
As Required by Law.
We will disclose medical information about you when required to do so by federal, state or local law. For example, Ohio law requires health care providers to report cases of child abuse.
To Avert a Serious Threat to Health or Safety.
We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.
Public Health Activities.
We may disclose medical information about you for public health activities such as the prevention or control of disease, injury or disability; reporting of births and deaths; reporting of child abuse or neglect; and, reporting of reactions to medications or problems with products and to fulfill requirements of the U.S. Food and Drug Administration.
Health Oversight Activities.
We may disclose medical information to a health oversight agency for activities allowed by law such as audits, investigations, inspections and licensure or disciplinary actions.
Lawsuits and Disputes.
We may disclose medical information about you in response to a Court Order, Administrative Order or certain subpoenas.
We may release medical information to a law enforcement official about a death we believe may be the result of criminal conduct; about criminal conduct at the hospital or health care facility; and, in emergency circumstances, to report a crime, the location of a crime or victims, or the identity, description or location of the person who committed the crime.
Coroners, Medical Examiners and Funeral Directors.
We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medical information to funeral directors as necessary to carry out their duties.
Military and Veterans.
If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
National Security and Intelligence Activities.
We may release medical information about you to authorized federal officials for intelligence and other national security activities authorized by law.
Protective Services for the President and Others.
We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.
If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or the law enforcement official.
OTHER USES OF YOUR MEDICAL INFORMATION:
The following uses and disclosures of your medical information will be made only with your written permission (your written permission is referred to as an authorization): (i) most uses and disclosures of notes recorded by a health care provider who is a mental health professional documenting or analyzing the contents of conversation during a counseling session and that are separated from the rest of the medical record (if maintained by us); (ii) uses and disclosures for marketing; (iii) uses and disclosures for research (unless authorization is not required as determined through the special approval process described above) and (iv) disclosures that constitute a sale of PHI. Other uses and disclosures of your medical information not covered by this Notice or required by the laws that apply to TriHealth, will be made only with your authorization.. If you provide your permission to use or disclose medical information about you, you may revoke that permission in writing at any time. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons indicated in your written Authorization. You understand that we are unable to take back any disclosures that we made before we received your written notice revoking your Authorization.
YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU:
You have the following rights regarding medical information we maintain about you:
Right to Inspect and Copy.
You have the right to inspect and obtain a copy of your medical information. This includes your medical and billing records but does not include psychotherapy notes. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request.
To inspect or obtain a copy of your medical information, you must submit your request in writing to TriHealth’s Privacy Officer, TriHealth, Inc., Corporate Administration Department, 619 Oak Street, Cincinnati, Ohio 45206.
We may deny your request in certain circumstances. If you are denied access to your medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by TriHealth will review your request and the denial. The person conducting the review will not be the same person who denied your request. We will comply with the outcome of the review.
Right to Amend.
If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long the information is kept by or for the hospital or health care facility.
To request an amendment to your medical information, you must submit your request for an amendment, along with your reason for the request, in writing to TriHealth’s Privacy Officer, TriHealth, Inc., Corporate Administration Department, 619 Oak Street, Cincinnati, Ohio 45206.
We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
- Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
- Is not part of the medical information kept by or for the hospital or health care facility;
- Is not part of the information which you would be permitted to inspect and copy; or,
- Is accurate and complete.
Right to an Accounting of Disclosures.
You have the right to request an “accounting of disclosures”. This is a list of the disclosures we made of your medical information. This list will not include disclosures that we made for purposes of treatment, payment and health care operations. We are also not required to include in this list the disclosures we made by acting upon your written authorizations.
To request an accounting of disclosures, you must submit your request in writing to TriHealth’s Privacy Officer, TriHealth, Inc., Corporate Administration Department, 619 Oak Street, Cincinnati, Ohio 45206.
Your request must state a time period which may not be longer than six (6) years and may not include dates before April 14, 2003. The first accounting you request within a twelve (12) month period will be free. For additional accountings, we may charge you for the costs of providing the list.
Right to Request Restrictions.
You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment, or health care operations. You also have the right to request a restriction or limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend.
We are not required to agree to your request for a restriction or limitation. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment.
In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse.If you paid in full and out of pocket at the time of your appointment and you request that the information related to that specific date of service for which you paid in full not be shared with your health plan for payment or health care operations, we will honor your request.
Right to Request Confidential Communications.
You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work.
We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
Right to a Paper Copy of this Notice.
You have a right to a paper copy of this Notice. You may ask us to give you a copy of this Notice at any time. You may also obtain a copy of this Notice at our website, at http://www.trihealth.com.
CHANGES TO THIS NOTICE:
We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current Notice in school at which you receive services under the School-Based Program. The Notice will contain on the first page, in the top right-hand corner, the effective date.
FOR FURTHER INFORMATION:
For further information about the matters covered by this Notice, you may contact the TriHealth’s Privacy Officer at 513-569-6507.
If you believe your privacy rights have been violated, you may file a complaint with TriHealth or with the Secretary of the U. S. Department of Health and Human Services. To file a complaint with TriHealth, you must submit your complaint in writing as follows:
Send your written complaint to the attention of TriHealth’s Privacy Officer, TriHealth, Inc., Corporate Administration Department, 625 Eden Park Drive, Cincinnati, Ohio 45206.
You will not be retaliated against for filing a complaint.